Persons Covered

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..... of India and the Kingdom of Norway for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income and on capital signed on 2nd February, 2011 (the Agreement ), as modified by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting signed by the India and Norway on 7th June, 2017 (the MLI ). The document was prepared on the basis of the MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of Norway submitted to the Depositary upon ratification on 17th July, 2019. These MLI positions are subject to modifications as provided in the MLI. Modifications made to MLI positions could modify th .....

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..... nglish) can be found at the following link: In India: https://www.incometaxindia.gov.in/Pages/international-taxation/dtaa.aspx In Norway: - https://www.regjeringen.no/no/dokumenter/prop-140-s-20102011/id649577/?q ch=6 The MLI position of India submitted to the Depositary upon ratification on 25th June, 2019 and of the MLI position of the Norway submitted to the Depositary upon ratification on 17 th July, 2019 can be found on the MLI Depositary (OECD) webpage. Entry into Effect of the MLI Provisions: The provisions of the MLI applicable to the Agreement do not take effect on the same dates as the original provisions of the Agreement. Each of provisions of the MLI could take effect on different dates, depending on the types of taxes involved .....

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..... ncome and on capital and with a view to promoting economic cooperation between the two countries, The following paragraph 1 of Article 6 of the MLI is included in the preamble of this Agreement: ARTICLE 6 OF THE MLI- PURPOSE OF A COVERED TAX AGREEMENT Intending to eliminate double taxation with respect to the taxes covered by this agreement without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this agreement for the indirect benefit of residents of third jurisdictions), have agreed as follows: ARTICLE 1 PERSONS COVERED This Agreement shall apply to persons who are residents of one or both of the Contracting S .....

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